Conflicts of Interest Policy

Raymond James recognises that, in the course of its business, there are circumstances which may give rise to a conflict of interest entailing material damage to its clients.

This page identifies those circumstances and sets out the specific measures that Raymond James employs to manage these actual or potential conflicts of interest.

Dealing as principal

Raymond James Investment Services does not hold principal positions in securities, or deal on its own account. However, we are associated with Raymond James & Associates (RJ&A) in the United States of America, which does.

The supervision and remuneration of Raymond James Wealth Managers is not connected to RJ&A’s activity as a market maker. Moreover, orders placed by Raymond James Wealth Managers with RJ&A are subject to RJ&A’s own execution policy (based on the rules of the Financial Industry Regulatory Authority ‘FINRA’), which ensures that a client’s order may not be traded on RJ&A’s own book if it is not in the best interests of the client. Contract notes clearly indicate where the counterparty was RJ&A.

Investment Research

Raymond James does not procure or produce its own investment research, however RJ&A does. RJ&A operates an independence policy that creates information barriers to control exchanges of information relating to investment research undertaken by RJ&A.

These information barriers prevent Raymond James Wealth Managers from accessing price-sensitive investment research undertaken by RJ&A before it is made public. Moreover, the supervision and remuneration of Raymond James Wealth Managers is not connected in any way with RJ&A’s activities in this area.

Personal dealing by officers and associates of Raymond James

Raymond James Wealth Managers may hold positions in securities that they are recommending to their clients. Raymond James has a policy that controls personal account transactions undertaken by Raymond James Wealth Managers and their employees, and head office staff. This policy ensures that personal account transactions do not disadvantage, or conflict with the interests of, Raymond James’s clients. For example, Raymond James ensures that any trades undertaken by a Wealth Manager in the same security as his/her clients on the same day are placed at the ‘back of the queue’ in terms of price and execution.

Raymond James also makes clear in its marketing communications the circumstances in which a Wealth Manager may be holding personal positions in any securities mentioned.

Gifts and inducements

Raymond James operates a policy that obliges Wealth Managers to declare any gifts or inducements that they have received over the value of £100. Wealth Managers maintain a register of these gifts and these are reviewed by Raymond James on a quarterly basis.

This policy also applies to Raymond James Head Office Staff except that gifts or inducements proffered in this instance have to be declared if over the value of £50.

Conflicts between clients

There are circumstances in which a number of Raymond James’s clients may be wishing to deal in the same security at the same time. Raymond James’ dealing procedures ensure that orders are either passed through our dealing desk, which is independent of Raymond James’ Wealth Managers, or they are entered onto an automated trading platform, which will ensure that the most advantageous outcome is obtained, regardless of the identity of the client.

Taking Raymond James Public

When consideration was being given to taking Raymond James public, Tom James penned a letter to shareholders (largely employees at the time).
He wrote:

” … the public offering should be considered as a statement of our independence. While this is a psychological rather than an economic rationale, it is nonetheless very important. We have asserted for some time that we are not interested in becoming a small part of a very large corporation. That assertion results mainly from the inclinations of management rather than the economic benefits associated with either alternative. The public stock offering affords us the opportunity to enjoy a little bit of the best of both worlds. While shareholders will be given liquidity at fair market value, we will still have the ability to control our own destiny.”

After 40+ years of Tom’s leadership, upon becoming CEO, Paul Reilly was often questioned about whether the company might ultimately surrender its cherished independence and be acquired by some larger entity. His response: “Not while I’m around.” It’s a theme that continues today.

Black Monday

On 19 October 1987, the stock markets experienced a dramatic plunge that prompted many firms to shut down their trading desks and turn off their phones to minimize internal losses. Raymond James refused to do the same. Our desks stayed open to help meet clients’ needs, resulting in our first and only unprofitable quarter since the firm went public in 1983.

Who was Raymond James?

The Raymond in our name is actually from Edward Raymond, owner of a 15-employee mutual fund sales group, Raymond and Associates, along Florida’s west coast. He sold his company to Bob James on 15 July 1964, on condition that the surviving firm be called Raymond, James & Associates.

Bear Market of 1974

The severe bear market of 1974 threatened the existence of Raymond James, which was bleeding capital by the day. Tom James, his father and other leaders took extreme measures to keep the firm afloat, slashing costs, foregoing paychecks and even attempting to sell the firm for just enough capital to protect client assets and retain as many associates as possible. The story could have ended very differently if not for a sharp upturn and continued rebound in the stock markets late in the year.
This “fortunate near-death experience” (as Tom calls it) permanently marked his psyche, and has influenced our firm’s character and culture since, solidifying the conservative nature that emphasizes a determined focus on the long term – both for clients and the firm.